by John Burnett:
You have to go back to the definitions for the regulation, because the regulation covers consumer accounts. An "account" for the purposes of the regulation is an account that is established primarily for personal, family or household purposes. A sole proprietor's business account doesn't fit the definition, so it's not covered.
by Randy Carey:
But you also have to pay attention to what disclosures you are providing the customer. If you are issuing personal debit cards to sole proprietors and giving them consumer disclosures, but treating them as a business for liability purposes, you might end up with an argument on your hands.